Privacy Policy

1. Introduction

Actionpack ("Actionpack," "we," "us," or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our website, mobile application, and related services (collectively, the "Services").

This Policy is designed to comply with applicable data protection laws in the jurisdictions where we operate, including but not limited to:

  • United Arab Emirates (UAE): Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data ("PDPL"), and applicable free zone regulations (e.g., DIFC Data Protection Law, ADGM Data Protection Regulations) where relevant.
  • United Kingdom (UK): UK General Data Protection Regulation ("UK GDPR") and the Data Protection Act 2018.
  • United States (USA): Applicable federal and state privacy laws, including the California Consumer Privacy Act ("CCPA")/California Privacy Rights Act ("CPRA"), and other state privacy laws as applicable.

By using our Services, you agree to the collection and use of information in accordance with this Policy. If you do not agree, please discontinue use of the Services.


2. Information We Collect

2.1 Information You Provide to Us

  • Account information (name, email address, phone number, username, password)
  • Billing and payment information (processed via third-party payment processors)
  • Profile information (photo, preferences, demographic details)
  • Communications with us (support requests, feedback, survey responses)
  • Content you upload, post, or submit through the Services

2.2 Information Collected Automatically

  • Device information (device type, operating system, browser type, unique device identifiers)
  • Usage data (pages viewed, features used, time spent, click patterns)
  • Location data (approximate location via IP address; precise location only with your consent)
  • Log data (IP address, access times, referring URLs)
  • Cookies and similar tracking technologies (see Section 8)

2.3 Information from Third Parties

  • Social media platforms (if you log in or link accounts)
  • Business partners, resellers, or affiliates
  • Publicly available sources
  • Analytics and advertising partners

3. How We Use Your Information

We use the information we collect to:

  1. Provide, operate, maintain, and improve the Services
  2. Process transactions and send related information
  3. Communicate with you, including customer support, updates, and marketing (subject to your preferences)
  4. Personalize your experience and deliver relevant content
  5. Monitor and analyze usage trends and preferences
  6. Detect, prevent, and address fraud, security issues, and technical problems
  7. Comply with legal obligations and enforce our terms
  8. Conduct research and development to improve our offerings

4. Legal Basis for Processing (UK/UAE)

Where required under UK GDPR or the UAE PDPL, we rely on one or more of the following legal bases to process your personal data:

  • Consent — where you have given clear consent for a specific purpose
  • Contractual necessity — processing necessary to perform a contract with you
  • Legal obligation — processing necessary to comply with the law
  • Legitimate interests — processing necessary for our legitimate business interests, provided these do not override your rights and interests

5. How We Share Your Information

We do not sell your personal information for monetary consideration. We may share information with:

  • Service providers who perform services on our behalf (hosting, analytics, payment processing, customer support)
  • Business partners for joint offerings, with your consent where required
  • Legal and regulatory authorities where required by law, court order, or governmental request
  • Successors in connection with a merger, acquisition, or sale of assets
  • Third parties with your consent or at your direction

6. International Data Transfers

Actionpack operates across multiple jurisdictions, and your information may be transferred to, stored, and processed in countries other than your country of residence, including the UAE, UK, USA, and other countries where our service providers operate.

  • UK transfers: Where we transfer personal data outside the UK, we rely on adequacy regulations, Standard Contractual Clauses (SCCs), the UK International Data Transfer Addendum, or other approved safeguards.
  • UAE transfers: We ensure appropriate safeguards are in place consistent with PDPL requirements for cross-border data transfers.
  • USA transfers: We implement contractual and technical safeguards for data transferred to or from the United States.

7. Data Retention

We retain personal information only for as long as necessary to fulfill the purposes outlined in this Policy, unless a longer retention period is required or permitted by law (e.g., tax, accounting, or legal reporting requirements). When information is no longer needed, we securely delete or anonymize it.


8. Cookies and Tracking Technologies

We use cookies, web beacons, SDKs, and similar technologies to:

  • Enable core functionality
  • Remember preferences
  • Analyze usage and performance
  • Deliver targeted advertising (where applicable and with consent where required)

You can manage cookie preferences through your browser settings or our cookie consent banner. Disabling certain cookies may affect functionality of the Services.


9. Your Privacy Rights

9.1 UK Residents (UK GDPR)

You have the right to:

  • Access your personal data
  • Rectify inaccurate data
  • Erase your data ("right to be forgotten")
  • Restrict or object to processing
  • Data portability
  • Withdraw consent at any time
  • Lodge a complaint with the Information Commissioner's Office (ICO)

9.2 UAE Residents (PDPL)

You have the right to:

  • Request access to your personal data
  • Request correction or deletion
  • Object to or restrict certain processing
  • Withdraw consent
  • Data portability, where applicable
  • Lodge a complaint with the UAE Data Office

9.3 US Residents (CCPA/CPRA and other applicable state laws)

Depending on your state of residence, you may have the right to:

  • Know what personal information is collected, used, shared, or sold
  • Delete personal information we hold about you
  • Correct inaccurate personal information
  • Opt out of the sale or sharing of personal information and targeted advertising
  • Limit use of sensitive personal information
  • Non-discrimination for exercising your rights

To exercise any of these rights, contact us using the details in Section 13. We may need to verify your identity before fulfilling a request.


10. Data Security

We implement appropriate technical and organizational measures designed to protect personal information against unauthorized access, alteration, disclosure, or destruction, including encryption, access controls, and regular security assessments. However, no method of transmission or storage is 100% secure, and we cannot guarantee absolute security.


11. Children's Privacy

Our Services are not directed to children under the age of 13 (or the applicable minimum age in your jurisdiction), and we do not knowingly collect personal information from children. If we become aware that we have collected personal information from a child without parental consent, we will take steps to delete it.


12. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will notify you of material changes by posting the updated Policy on our website or through the Services, with the "Last Updated" date revised accordingly. Continued use of the Services after changes take effect constitutes acceptance of the updated Policy.


13. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

Actionpack Email: info@apdxb.com 

  • UK residents may also contact the ICO: www.ico.org.uk
  • UAE residents may also contact the UAE Data Office
  • California residents may also contact the California Attorney General's office